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Player Complaints Policy Guidelines Version 1.1 18th June 2025

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1 Policy Overview

This Complaints Policy outlines the framework for managing player complaints and disputes, ensuring a transparent, fair, and efficient process in alignment with the requirements under Article 5.3 of the National Ordinance on Games of Chance (Landsverordening op de kansspelen, “LOK”).

Adherence to this Complaints Policy is considered a requirement under the LOK, and failure to comply will be addressed by the Curacao Gaming Authority (CGA) in accordance with its supervision, monitoring and enforcement procedures.

The Complaints Policy guarantees players access to a straightforward and effective complaint and dispute resolution process, including free alternative dispute resolution (ADR) services that prioritize quality and independence.

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In accordance with Article 5.3 of the LOK, further rules, policies and guidelines regarding complaints and ADR processes may be established and implemented from time to time. These will be published and made available on the CGA website.

• The operator’s player complaints policy must be clearly included or referenced in the operator’s Terms and Conditions. It must include details of all Stages of Complaint Resolution (Clause 3.2)

  • The operator may, at its own discretion, publish the policy as a “standalone” document with link(s) from the website homepage and/or registration page.
  • The operator may, at its own discretion and subject to compliance with applicable private law, require the player to explicitly confirm acceptance of the Complaints policy in any way including a tick box, popup or email.
  • The operator may, at its own discretion, include acceptance of the Complaints policy as part of its registration process.

This Complaints Policy is based on regulatory requirements under the LOK. It does not affect or override the applicable rules of private law, including, but not limited to, the provisions of Book 6 of the Civil Code of Curaçao concerning general terms and conditions. Operators remain responsible for ensuring compliance with all relevant civil law obligations independently of this policy. They are expected to seek appropriate legal advice to ensure that their complaints procedures and terms and conditions conform to private law requirements.

2 Definitions

2.1 Player Interaction

Any written communication initiated by a player and directed to the operator’s customer service team. This includes general enquiries, feedback, or requests for information, assistance, or clarification.

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2.2 Complaint

A Complaint is a written expression of dissatisfaction by a player relating to the operator’s services, decisions, terms, or conduct, which indicates the player is unhappy and expects a response or resolution. For the purpose of Reporting requirements (Clause 6) a complaint is when a Complaint Submission Form (Clause 3.2 paragraph 3) has been submitted by the player to the operator and/or a complaint has been escalated to ADR.

2.3 Dispute

A complaint that has not been resolved to the player’s satisfaction through the internal complaints process and has been escalated, either within the organisation or to an independent third party (e.g. an ADR provider or court of law).

3 Complaint Submission Process

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3.1 Complaint Window

1. This Complaints Policy applies to all players of operators licensed under the LOK from the date of licence issuance, and to all operators licensed under the NOOGH regime from the moment they were issued a green or orange dynamic seal.

2. Players may lodge a complaint free of charge at any time up to six months of the settlement of the bet or the incident about which they are making a complaint.

3. In the case of P2P (such as poker) or ante post fixed odds betting the six month clock begins after the bet settlement or conclusion of a specific event rather than the placement of the wager.

4. In the case of complaints about in-running sports betting, customers must be advised that while they may submit a complaint within six months, prompt action may be necessary if the investigation may depend on data specific to the complaint which — due to the nature of inrunning betting — may no longer be available after a short period, insofar as the operator cannot reasonably be expected to preserve such data any longer…

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3.2 Stages/Escalation of Complaint Resolution

1. Complaints can only be made by the registered player. Article 1.3 section c of the LOK mandates that a player is not allowed to sell, donate, rent out, lease, pawn, or pledge, under any title, any of their claims against the holder of a gaming license from the CGA.

2. In the first instance the operator must offer customer support via email and/or live chat.

3. An official Complaint Submission Form must be available to the player.

a. This form must be either a downloadable form that can be completed and emailed or otherwise uploaded by the player, and/or a form that is fully completed and submitted online.

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b. The form must include at a minimum the following sections

i. Complainant’s name, address, and place of residence.

ii. Complainant’s account number (if applicable) iii. Date of the complaint and date of the disputed event.

iv. Description of the conduct being disputed (using a selection of predetermined category topics if/as applicable).

c. The form must be available in English and in the language of the website/domain that the player is using.

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d. The operator may request supporting documentation the player requires to include as part of the complaint. Any additional information or documentation requested by the operator must be a reasonable in the context of complaint resolution.

4. The operator must offer an ADR option for the players, subject to the requirements of Clause

5.

5. Except if mutually agreed under specific terms of ADR (Clause 5), the operator must not restrict the rights of the player him/herself to take legal action.

3.3 Role of the CGA

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1. It is the responsibly of the operator to make the role of the CGA clear to the player in the Terms and Conditions.

2. The CGA will not resolve or make decisions on any player complaints regarding gamblingrelated transactions on the operator’s website(s).

3. Unless deemed to be inadequately handled, the decisions made by the operator and/or ADR provider will not be subject to reviewing and/or overturning by the CGA

4. Notwithstanding 2. and 3. above the operator must not restrict the player’s ability to contact the CGA directly with regard to matters including but not limited to malpractice, breach of license conditions or whistleblowing.

5. While the CGA does not mediate in individual disputes it will use the information to support its supervisory and enforcement actions.

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4 Complaint Resolution Process

4.1 Timeline: Responsible Gaming Complaints

Complaints related to responsible gaming should be prioritized due to potential impacts on player well-being. Complaints should be categorized as related to responsible gaming in any case when it regards targeting of Vulnerable Players, the availability and/or timely implementation of self-exclusion and/or cooling-off and the mandated consequences therein as outlined in the Responsible Gaming policy.

Operators must use best in efforts to resolve these cases within five business days.

Within two days of receiving a complaint, the operator will:

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• Confirm receipt of the complaint in writing.

• Provide an explanation of how the complaint will be processed.

• Provide notice of the average timeline for resolution of such complaints.

If more time is needed by the operator to make a reasonable and informed decision, players must be informed of the delay, which cannot exceed two weeks. If a delay is due to a lack of or a slow response from the player, the resolution period may be extended by no more than a further two weeks.

4.2 Timeline: All Other Complaint Types

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The operator will assess and respond to complaints within four weeks. If necessary, due to complexity or lack of information, this period may be extended once by an additional four weeks, with prior written notice to the player.

Within one week of receiving a complaint, the operator will:

• Confirm receipt of the complaint in writing.

• Provide an explanation of how the complaint will be processed.

• Provide notice of the average timeline for resolution of such complaints.

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4.3 Response and Resolution

A player will always receive a final determination of their complaint in writing.

The response will be either:

1. A reasoned final assessment of the outcome/resolution of the complaint with supporting evidence if necessary or applicable.

2. Detailed reasons for not handling the complaint. If additional information is reasonably required to address the complaint fully, the operator must have requested this information within the initial four week time period. Should the complainant not provide the necessary information within that time period, the operator may reject the complaint.

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3. If the player is unsatisfied with the resolution and makes a further complaint to that effect, the player is informed that they may escalate the matter to an independent ADR entity.

4.4 Artificial Intelligence (AI)

The use of AI is permissible under this Complaints Policy Guideline subject to the following terms:

1. Once a player complaint has been identified as pertaining to Responsible Gaming

(Clause 4.1), communications with the player should be conducted by a human, not AI.

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2. Complaints that can be reasonably considered as complex should be dealt with by a human, not AI.

3. The AI records must be monitored to ensure that they are reasonable in their solutions/recommendations and consistent across players with like-for-like complaints.

5 Alternative Dispute Resolution

In order to be compliant with their license conditions as mandated by LOK, each licensed operator must offer independent ADR services to their players in accordance with the ADR Policy.

1. Full details of the ADR process must be included in the operator’s Terms and Conditions.

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2. Operators must have uploaded to the CGA Portal an agreement with at least one CGA Certified ADR entity, within one month of the publication of the Certified ADR Providers on the official website.

3. If a complaint cannot be resolved internally, players are entitled to escalate the matter to an independent ADR provider, free of charge. For avoidance of doubt, the operator will bear all costs of the ADR process.

4. Once ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

5. In the event that the player drops out of the ADR process (but it has already begun) – it should be noted the player should not have the right to resurface the dispute in the future.

6. Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

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Furthermore, the CGA will take all relevant circumstances into account when assessing whether the operator’s measures to prevent abuse are justified. For example, the CGA may understand that in cases involving very low-value claims there may be a legitimate concern about potential misuse.

At the same time, each case must be assessed on its own merits. For instance, if a claim concerns the admission of a self-excluded person, the CGA expects the matter to be taken seriously, regardless of the monetary value involved.

6 Record-Keeping and Reporting

The operator will:

1. Submit reports to the CGA on January 15th and June 15th based on complaints submitted to the operator since the previous reporting period by players using the Complaints Submission Form. The first reports become due in January 2026.

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2. The report will summarise the following:

a. Total number of complaints made.

b. Total number of settled complaints (upheld and rejected).

c. Number of pending or unresolved complaints.

d. Number of complaints by category.

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e. Number referred to ADR.

f. Number and detail of complaints for which a player has taken legal action.

3. Ensure transparency and compliance with ADR decisions and regulatory updates.

4. ADR service providers will have their own reporting requirements in accordance with the Alternative Dispute Resolution policy issued by the CGA.

5. Records of unresolved complaints and/or complaints that have been escalated to ADR or legal proceedings will be kept for the lesser of five years or the relevant time stipulated by data protection, statute of limitations or other relevant laws or guidelines.

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6. The CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution.

7 Terms and Conditions

The Complaints procedure statement will be visible and accessible on the operator’s website as a standalone link or document.

The Complaints procedure will also be clearly outlined in the Terms and Conditions.

Information provided will include at a minimum:

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1. Links to customer service and information on how to contact the operator.

2. Detail of information required for a player to make a complaint and links to either/both either the online form or the downloadable PDF/Word document.

3. Timelines for responses and resolution.

4. Player rights to complain including explicit rights to ADR services and regulatory escalation.

5. An explanation of the potential consequences of the relevant ADR entity’s decision, and the manner in which this will affect the player’s right to further legal and judicial recourse.

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6. Details of the ADR process and player rights.

7. Contact information for the ADR provider(s)

8. Clear information that the CGA does not mediate in individual disputes, but if the player feels the operator is in breach of regulations that the player may contact the CGA.

8 Reasons for Complaint

The player has the right to make a complaint regarding any part of their relationship with the operator, or any incident related to their participation in a game of chance. This includes (but is not limited to):

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1. Deposit issues

2. Withdrawal issues

3. Bonus terms and conditions

4. Account closures or restrictions

5. Alleged errors or unfairness in game outcomes

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6. Responsible gaming issues

7. Treatment of player balances

8. KYC and Verification

9. Data Protection

10. Technical or Software issues

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11. AML concerns

12. Issues with minors

13. Fraudulent games

14. Fraudulent practices

15. License or regulation

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16. Unfair terms and conditions

9 Transition Deadline

The Complaints Policy must be uploaded to the CGA Portal no later than 31st July 2025.

 

 

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The post Player Complaints Policy Guidelines Version 1.1 18th June 2025 appeared first on European Gaming Industry News.

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N1 Partners is giving away a trip to a surf camp at SBC Summit 2025 in Lisbon

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Surf On the Waves to Success: N1 Partners at SBC Summit Lisbon 2025

From September 16 to 18, the N1 Partners team will take part in SBC Summit 2025 in Lisbon — one of the largest events in the iGaming industry. Thousands of professionals from around the world will gather at Feira Internacional de Lisboa & MEO Arena to discuss trends, exchange insights, and build new partnerships. N1 Partners is known for preparing something special for every event, and this time the team will bring a vibrant surf-inspired atmosphere to booth F84.

Surfing the Wave of Opportunities with N1 Partners

At every conference, meeting the N1 Partners team is a chance for affiliates to advance in the N1 Puzzle Promo and get closer to the grand prize of the year — the Robinson R22 Beta II helicopter. In Lisbon, this journey takes on a fresh theme — surfing, as a symbol of freedom, energy, and moving forward.

At the N1 Partners booth, the team will recreate the vibe of a real surf camp, giving partners the chance to discuss business opportunities and take part in activities designed to help them “catch the wave” of success.

What Visitors Will Find at Booth F84

  • Surf Bar serving signature bubble teas and retro-surf–style cocktails
  • Surf Balance Board Challenge: test your balance, claim guaranteed prizes, and get the chance to win an all-inclusive surf trip
  • Meeting zones designed for productive negotiations and top-tier deals in a comfortable setting

A Dream Trip for the Winner

N1 Partners will raffle off a certificate for an all-inclusive surf camp trip, which includes flights, villa accommodation, training with a professional coach, and a branded surfboard delivered directly to the winner.

How to participate:

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  1. Visit booth F84
  2. Register for the giveaway
  3. Be present at the raffle (stay tuned for the exact time on N1 Partners’ social media)

Full terms and conditions will be available at the booth.

See You in Lisbon

SBC Summit Lisbon is the perfect opportunity to meet the N1 Partners team, explore new projects, learn about the latest brand launches, and discuss exclusive partnership opportunities. At booth F84, visitors will find live business conversations, branded merch, and additional puzzles to bring them closer to the grand prize of the N1 Puzzle Promo.

Why N1 Partners

Working directly with an advertiser, partners of N1 Partners benefit from:

  • 14+ licensed casino and sportsbook brands with Reg2Dep up to 70%
  • top deals across 10+ Tier-1 GEOs
  • CPA up to €650, RevShare up to 45% + NNCO, and hybrid models 

At booth F84, the N1 Partners team will be focused on real business. Whether you run SEO, PPC, FB, or other traffic sources, you’ll discover how to turn them into even greater profit with N1 Partners’ offers.

Don’t wait: book your meetings with N1 Partners’ affiliate managers now and make your SBC Lisbon experience as productive as possible.

The post N1 Partners is giving away a trip to a surf camp at SBC Summit 2025 in Lisbon appeared first on Gaming and Gambling Industry in the Americas.

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BOS in letter to the Government: appoint a new Gambling Inquiry

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BOS – The Swedish Trade Association for Online Gambling – is today sending a letter to the Ministry of Finance with a proposal to appoint a new gambling inquiry. The inquiry’s task should be to propose measures that strengthen the proportion of legal, licensed gambling in Sweden, that is, the so-called channelization.

The Swedish Gambling Authority confirmed earlier this week in a report that the state’s goal with the gambling policy regarding its channelization is not being reached. The goal is at least 90 percent channelization, but Sweden only reaches 85 percent. And for online casino, the product category where it is most important for consumer protection reasons that the proportion of legally licensed gambling is the highest, it is actually the lowest (72-82%).

During September this year, government investigator Marcus Isgren is expected to present a proposal that aims to strengthen channelization within one area, namely the so-called scope of application of the Gambling Act. It is a welcome proposal, but few stakeholders believe that this single adjustment is enough to achieve the goal of the gambling policy, at least 90 percent channelization.

For this reason, BOS is proposing today in its letter to the Ministry of Finance that the government appoint a new broad gambling inquiry, with the task of proposing measures that strengthen channelization in the Swedish gambling market. Among the proposals that should be considered, BOS mentions a somewhat less rigid regulation of loyalty bonuses, which are currently completely prohibited.

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BOS Secretary General Gustaf Hoffstedt comments:

“We hope that the government will take to heart the serious situation for the licensed gambling market, most recently confirmed in the Gambling Authority’s report on the proportion of unlicensed gambling in Sweden. The appointment of a broad inquiry tasked with preventing leakage to the unlicensed gambling market would undoubtedly be this government’s most important measure to protect and strengthen the legal regulated gambling market, before Sweden goes to the polls in September next year.”

The post BOS in letter to the Government: appoint a new Gambling Inquiry appeared first on European Gaming Industry News.

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MightyTips partners with BigClash.com to boost engagement and growth

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MightyTips has announced an exciting new partnership with BigClash.com, a dynamic online gaming platform, to enhance brand visibility, drive quality traffic, and deliver greater value to players worldwide.

Eugene Ravdin, Head of PR at SEOBROTHERS, said: “Collaborating with BigClash.com is a natural step in MightyTips’ mission to connect audiences with trusted, engaging platforms. Their innovative approach to online gaming makes them a perfect fit for our network, and we’re looking forward to building long-term success together.”

BigClash.com offers a premium online entertainment experience, combining cutting-edge sports betting and interactive casino gaming with a strong emphasis on user satisfaction. The platform is designed for accessibility, excitement, and player trust, backed by secure operations and responsible gaming standards.

Dan, Head of Affiliates at BigClash.com, commented: “Partnering with MightyTips marks an important milestone for BigClash.com. Their expertise in affiliate marketing and proven ability to generate engaged players make them an ideal ally as we continue to grow. MightyTips delivers visibility and meaningful connections with the right audiences. We’re excited about what lies ahead.”

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This collaboration is set to strengthen BigClash.com’s position in key global markets, while further diversifying MightyTips’ portfolio with another reputable and fast-growing partner.

The post MightyTips partners with BigClash.com to boost engagement and growth appeared first on European Gaming Industry News.

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